FBAR Quiet disclosures
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Quiet Disclosure Guilty Plea

Florida man pleads guilty to tax evasion and hiding funds around the world In April 2020, a Florida man pleaded guilty to tax evasion and the willful failure to file FBAR’s. What makes this case particularly interesting is that the taxpayer…
Investment Retirement Account

Real Estate Ownership in a self-directed Investment Retirement Account; avoiding the hidden risks

 Real estate ownership in a Self-Directed Investment Retirement Account (IRA) can provide certain tax benefits to taxpayers who are considering an investment in real estate. However, a retirement account considering such a strategy should be…
Michael Avenatti Case on Criminal Tax
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Bank Fraud and Criminal Tax Charges Against Michael Avenatti

Michael Avenatti’s Indictment The temptation to use unfilled or altered tax returns as well as doctored financial statements for purposes of securing a bank loan, while not common, does occur. This practice typically occurs where an individual…
Taxing Foreign Corporations
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Taxing Foreign Corporations in the Digital Age

Effectively Connected Income and it's Tax Consequences Foreign entities that deliver digital goods and services using the internet as a point of distribution may be subject to U.S. income tax. The nature and character of the goods and services…
Qualified Business Income Deduction 2

Good News for Rental Property Owners; Qualified Business Deduction

Business Income Deduction for Taxpayer On September 24, 2019, the IRS issued Revenue Procedure 2019-38  now permitting  certain taxpayers who hold an interest  or interests in rental real estate to be treated as a trade or business for purposes…
TFR and Fraudulent conveyances
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Trust Fund Recovery Penalty; Consequences of Fraudulent Conveyances

Fraudulent Conveyances in Employment Taxes Employers who willfully fail to remit an employee’s withholding to the IRS are liable to the IRS for the “trust fund recovery penalty” (TFRP). Generally, the IRS will assess the Penalty against…
Tax relief for renouncing citizenship 1
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Tax Relief for Expats who Renounce U.S. Citizenship

Relief Procedures for former U.S. Citizens The new procedures attempt to address problems faced by some U.S. citizens, whose only connection with the United States is that they were born in America. Many of these individuals have been living…
Employment taxes, IRS and workers classification

Employment Tax Consequences with Workers Misclassification

Employee versus Independent Contractor Deciding whether to classify an individual as an employee or independent contractor is a decision which requires a careful evaluation of many factors and the assistance of a tax attorney. A…